How to Manage an Effective Compliance Program in

How to Manage an Effective Compliance Program in a Decentralized Environment Kenya Mann Faulkner Chief Ethics & Compliance Officer April 2019 Office of Ethics and Compliance

Ethics & Compliance Mission • Support the University community in fulfilling its mission • Promote an ethical culture • Promote compliance with legal and regulatory obligations Office of Ethics and Compliance

Ethics & Compliance Organizational Chart

Office of Ethics & Compliance Units • • Athletics Compliance Athletics Integrity Commonwealth Campus Athletics Communications and Training Export Control Investigations University Ethics Youth Program Compliance Office of Ethics and Compliance

Compliance Plan 1. 0 2. 0 3. 0 4. 0 5. 0 6. 0 7. 0 8. 0 9. 0 10. 0 11. 0 Introduction/Objectives Compliance Risk Organizational Commitments to the Plan Oversight and Implementation Policies and Procedures Communications Responding to Reports Training and Education Risk Assessment Auditing and Monitoring Authority and Enforcement Office of Ethics and Compliance

Compliance Plan Updates • Specific objectives for the plan • Provisions for increased insight and collaboration with embedded compliance units • Further definition of roles and responsibilities of the CECO • Formal guidelines for responding to reports Office of Ethics and Compliance

E&C Council • Bimonthly meetings, 26 representatives • Goal: – To increase central awareness regarding violations of regulations and/or law – To better understand areas requiring monitoring or assistance – Make recommendations on training, education, and outreach to raise awareness of compliance • How it works: – Each meeting to include a report from a different unit – Council provides feedback – Unit returns in 2 -3 months to update Office of Ethics and Compliance